Episode 335 -- The New DOJ Whistleblower Program
Navigating the Labyrinth of Private Equity Investments in Health Care – Diagnosing Health Care
AGG Talks: Women in Tech Law Podcast - Episode 3: Cybersecurity and FCA Compliance: Essential Insights for Tech Leaders
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
#WorkforceWednesday®: New DOJ Whistleblower Program - What Employers Must Know - Employment Law This Week®
The Presumption of Innocence Podcast: Episode 43 - New Horizons: Impact of Recent Appellate Circuit Rulings on White-Collar Criminal Defense Law
Redlining Isn’t What it Used To Be
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
Episode 328 -- Sanctions Enforcement Risks and Redlines
Common Scenarios Triggering False Claims Act Violations, Part 1: Gov. Contracts and Cybersecurity
Cannabis Law Now Podcast: What’s Next for Schedule III Marijuana
Redlining Complications Caused by Implementation of 2020 Census Tracts
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
The Justice Insiders Podcast: DOJ’s Cacophony of Whistles
The Latest on Healthcare Enforcement
Perhaps the most significant blog post in the compliance arena was penned by Matt Ellis over 10 years ago when he challenged Walmart to “Go Big” on compliance. (They did.) We are now at another inflection point in compliance...more
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
False Claims Act (FCA) enforcement has routinely targeted false information supplied to Medicare and Medicaid. A new trend in false-reporting cases is emerging under the FCA’s broad authority — cybersecurity enforcement....more
The United States Environmental Protection Agency (“EPA”) issued a proposal to change the Resource Conservation and Recovery Act (“RCRA”) regulations to add nine per- and polyfluoroalkyl compounds (collectively, PFAS), their...more
The 2023 ECCP re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively...more
A recent article in Law360 sparked a vigorous conversation among members of Pietragallo’s white collar practice group about the current state of the U.S. Department of Justice’s (DOJ) evolving emphasis on individual...more
Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there. By following the roadmap, companies may escape...more
This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more
On December 18, 2023, new cybersecurity rules adopted by the U.S. Securities and Exchange Commission (SEC) became effective. Among other things, those rules require SEC registrants to disclose certain information about...more
As we discussed in our prior blog post, the Securities and Exchange Commission (SEC) recently finalized its Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rule for public companies (the "Rule")....more
On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more
The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more
On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more
Last month, U.S. Deputy Attorney General Lisa O. Monaco announced a new Safe Harbor Policy for voluntary self-disclosure (the “Policy”) made in connection with merger and acquisition activity. The Policy is intended to bring...more
Although the SEC has long adhered to its Seaboard Report of Investigation to outline the analytical framework for the agency's cooperation program for companies, the exact benefits of self-policing, self-reporting,...more
After conducting a thorough and privileged internal investigation, it becomes evident that your Company has overcharged the government over $50 million, and that the fraud was directed by a high-level manager. What do you do...more
On October 4, 2023, Deputy U.S. Attorney General Lisa O. Monaco announced that the United States Department of Justice (DOJ) is implementing a new nationwide Mergers & Acquisitions Safe Harbor Policy (the “M&A Policy”)....more
DOJ’s announcement of a safe harbor for voluntary self-disclosure in the context of acquisitions is the latest policy change in support of its effort to incentivize compliance, empower compliance professionals, and make...more
Continuing its focus on incentivizing prompt and voluntary self-disclosure of criminal misconduct, Deputy Attorney General Lisa Monaco announced earlier this month a new U.S. Department of Justice (DOJ) Safe Harbor Policy...more
On October 4, 2023, the Department of Justice’s (“DOJ”) Deputy Attorney General Lisa Monaco announced a new “Mergers & Acquisitions Safe Harbor Policy” (“M&A Safe Harbor Policy” or “Policy”) for companies that voluntarily...more
The United States Department of Justice (DOJ) recently announced a new department-wide Mergers & Acquisitions Safe Harbor Policy that protects acquiring companies that self-disclose criminal misconduct discovered at an...more
Under a new U.S. Department of Justice ("DOJ") policy related to mergers and acquisitions ("M&A"), DOJ will decline to prosecute an acquiring company for misconduct by an acquired company where the acquiring company timely...more
In an important policy announcement aimed at rewarding robust due diligence and compliance programs, DOJ announced that acquiring companies that promptly and voluntarily disclose criminal misconduct discovered at the acquired...more
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more